CBSA Memorandum D17-1-13: Interim Accounting (Master Provisional Entry – MPE)

In certain import transactions, goods may enter Canada before the final value, quantity, or complete shipment details are fully known. This commonly happens in large-scale industrial, engineering, infrastructure, and defence-related imports.

To manage these situations, the Canada Border Services Agency (CBSA) provides a special customs mechanism known as the Master Provisional Entry (MPE).

This system allows importers to account for goods on a provisional basis while final project details are still being determined.

1. Statement of Facts (Legal Situation)

Under normal customs rules, importers must submit a complete accounting declaration at the time goods are imported into Canada.

However, practical challenges arise when:

• The final value for duty has not yet been determined
• The total quantity of components remains uncertain
• The complete list of parts or materials is unavailable
• Goods arrive in multiple shipments over time

This situation commonly arises in:

• Large industrial machinery projects
• Construction or infrastructure installations
• Defence equipment imports
• Complex engineering systems
• Long-term phased delivery projects

To solve this issue, CBSA permits use of the Master Provisional Entry (MPE).

2. Administrative Policy (CBSA Treatment)

Under CBSA policy, Master Provisional Authorization may be granted for eligible project imports.

Typical eligible goods include:

• Construction project plans, drawings, and blueprints
• Large machinery and equipment for installation
• Defence equipment imported by the Department of National Defence
• Materials used for repair, maintenance, testing, or modification of military equipment

This facility is not automatic.

Before using MPE, the importer must:

• Submit a request through the CARM Client Portal (CCP)
• Obtain advance authorization from CBSA

Only after approval may provisional accounting proceed.

3. Evidence Required (Supporting Documents)

To obtain approval, the importer must submit documents proving the legitimacy and scope of the project.

Typical supporting documents include:

• Project description
• Project location
• Project schedule or timeline
• Contract agreement
• Responsible parties for installation or execution
• Ownership information
• List of materials, components, or equipment
• Port of entry details
• Estimated total import value

These documents help CBSA verify that the project is legitimate and provisional accounting is justified.

4. Accounting Procedure

Once CBSA grants Master Provisional Authorization, the importer must file a:

Commercial Accounting Declaration (CAD)

The CAD must include:

• The Master Provisional Authorization case number
• The authorization letter issued by CBSA
• Supporting release documentation

This serves as the primary accounting document for the provisional entry.

5. Payment Rules

As a general rule, duties and taxes are payable at the time of release.

However, importers enrolled in the Release Prior to Payment (RPP) program and maintaining required financial security may defer payment.

In such cases, payment is made according to the Statement of Adjustment due date issued by CBSA.

6. Subsequent Shipments

Large project imports often arrive in multiple shipments over time.

After the initial CAD is filed, later shipments may be released on a:

“Value Included” basis

These shipments may also use the:

RMD – Release on Minimum Documentation procedure.

This allows continued movement of goods while overall accounting remains under the Master Provisional Entry.

7. Final Adjustment

Once the project is completed or the final shipment arrives, the importer must complete final accounting adjustments.

This may involve:

• Payment of additional duties
• Claiming a refund if duties were overpaid

This final adjustment must be completed within 12 months of:

• Project completion, or
• Receipt of the final shipment

8. Refund Rule

If duplicate duties are paid or overpayment occurs during the provisional accounting process, the importer may apply for a refund.

Such refunds may be claimed under:

Section 74(1)(d) of the Customs Act

9. Tariff Treatment Rules

If preferential tariff treatment is being claimed, it must be declared in the Master Provisional Entry application.

Examples include:

• United States Tariff
• Mexico Tariff
• Canada–Israel Agreement Tariff
• Canada–Chile Agreement Tariff

The importer must also provide the required Certificate of Origin to support the claim.

10. Pith and Substance

The core principle of Memorandum D17-1-13 is to provide a provisional accounting system for complex project imports.

This enables legitimate trade to continue efficiently while allowing CBSA to maintain oversight and properly assess final duties and taxes once complete information becomes available.

11. Jurisprudential Philosophy

Trade Facilitation with Regulatory Control

The objective of CBSA policy is to:

• Facilitate legitimate international trade
• Protect government revenue
• Ensure compliance with customs legislation

The Master Provisional Entry system reflects this balance by providing flexibility for large projects while preserving CBSA’s authority to verify and finalize duty assessments.

Disclaimer

This article is prepared for educational and informational purposes only.

It does not constitute legal advice. Importers should consult CBSA, a licensed customs broker, or a qualified barrister or solicitor for professional guidance regarding customs compliance.